EPA Releases Draft Guidance on PFAS SNUR

Posted on: December 17, 2020

by John J. Kowalski, CHMM

On July 27, 2020, the U.S. Environmental Protection Agency (EPA or the Agency) finalized a Significant New Use Rule (SNUR) for Long-Chain Perfluoroalkyl Carboxylate (LCPFAC) and Perfluoroalkyl Sulfonate Chemical Substances.  This action was required by Section 7352 of the National Defense Authorization Act for Fiscal Year 2020 (NDAA).  See our previous article entitled “U.S. Congress Addresses PFAS” for additional information regarding the NDAA.

The final SNUR, which amended the regulations codified at 40 CFR § 721.9582 and 40 CFR § 721.10536, had an effective date of September 25, 2020.  Among other things, it requires persons to notify EPA at least 90 days before importing a subset of LCPFAC chemicals as part of a surface coating on articles.  It will also preclude the importation of such articles until the Agency has conducted a review of the notice, made an appropriate determination on the notice, and taken such actions as are required in association with that determination.

On December 16, 2020, EPA announced the availability of a draft compliance guide for the import of articles with certain LCPFAC chemicals as part of a surface coating.  According to the Agency, the draft compliance guide provides additional clarity on what is meant by a ‘‘surface coating,’’ identifies which entities are regulated, describes the activities that are required or prohibited, and summarizes the notification requirements of the final SNUR.  Comments on the draft compliance guide must be received on or before January 15, 2021.

Recommended Action Items

  • Review the draft compliance guide; and
  • Consider submitting comments.


Environmental Protection Agency.  “Draft Compliance Guide for Imported Articles Containing Surface Coatings Subject to the Long-Chain Perfluoroalkyl Carboxylate and Perfluoroalkyl Sulfonate Chemical Substances Significant New Use Rule; Notice of Availability and Request for Comment.”  Federal Register 85 (16 December 2020): 81466-81468.  2020-27600.pdf (


United States, EPA, SNUR, PFAS


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